RAND researchers respond to comments on three earlier reports related to post-operative visits bundled into Medicare payments for procedures. The authors remain confident in their main conclusion that fewer post-operative visits were provided than expected, leading to Medicare overpayment for some procedures and underpayment for other services. They recommend that the Centers for Medicare & Medicaid Services revalue procedures using the new data.

Responses to Comments on RAND Global Services Reports

Andrew W. Mulcahy, Ateev Mehrotra, Courtney A. Gidengil, Susan L. Lovejoy

ResearchPublished Feb 5, 2021

This report was initially published in 2019; this update was published in 2021 and includes clarification on RAND's definition of clean procedures.

In July 2019, as part of a contract with the Centers for Medicare & Medicaid Services (CMS), the RAND Corporation published three complementary reports related to post-operative visits bundled into Medicare payments for many procedures. The reports build on a new CMS requirement that some practitioners report on when bundled post-operative visits occur using a no-pay claim. CMS invited comments on these reports in the calendar year 2020 Physician Fee Schedule Proposed Rule. Although some organizations supported CMS's efforts to collect data on post-operative visits and the related RAND reports, others expressed concerns about CMS's claims-based data collection and the content of the reports. In this follow-up report, RAND researchers respond to those criticisms. The authors remain confident in their main conclusion that fewer post-operative visits were provided than expected, leading to Medicare overpayment for some procedures and underpayment for nonprocedure services, such as office visits. They recommend that CMS consider revaluing procedures with bundled post-operative visits in consideration of the newly available data on the number of post-operative visits actually provided to patients.

Recommendations

  • CMS should consider approaches to revalue procedures with bundled post-operative visits in consideration of the newly available data on the number of post-operative visits actually provided under Medicare's global payment policy. The three earlier RAND reports serve as a starting point for further discussion and policy development. The reports point to a significant disconnect between the number of post-operative visits that CMS assumes typically occur during global periods and the number of visits that actually occur under Medicare's global payment policy.
  • There are several paths forward that CMS could consider, including implementing the reverse building block approach described in our revaluation report and using a hybrid approach blending the reverse building block reductions in work relative value units with estimates of total work from magnitude estimation. CMS also could revisit its earlier proposal to unbundle post-operative visits from payment for procedures. Practitioners could then bill for and be paid for post-operative visits as they do for other evaluation and management visits.

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Citation

RAND Style Manual
Mulcahy, Andrew W., Ateev Mehrotra, Courtney A. Gidengil, and Susan L. Lovejoy, Responses to Comments on RAND Global Services Reports, RAND Corporation, RR-4314-1-CMS, 2021. As of September 20, 2024: https://www.rand.org/pubs/research_reports/RR4314-1.html
Chicago Manual of Style
Mulcahy, Andrew W., Ateev Mehrotra, Courtney A. Gidengil, and Susan L. Lovejoy, Responses to Comments on RAND Global Services Reports. Santa Monica, CA: RAND Corporation, 2021. https://www.rand.org/pubs/research_reports/RR4314-1.html.
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This research was funded by the Centers for Medicare and Medicaid Services (CMS) and conducted by the Payment, Cost, and Coverage Program within RAND Health Care.

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